Epstein Secrets

. Very truly yours, gag 51,44444s Bobbi C. Sternheim, Esq. cc: via email Mark S. Cohen, Esq. Christian R. Everdell, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. 6 EFTA00040356

within your facility. On July 14, 2020, the Honorable Alison J. Nathan entered an order of detention remanding Ghislaine Maxwell to the custody of the Bureau of Prisons. She has been detained since her arrest on July 2, 2020 and has been incarcerated at MDC under conditions that rival those at USP Florence ADMAX. A

of confinement during COVID pending in the Eastern District of New York before the Honorable Margo K. Brodie. See Federal Defenders of New York v. Federal Bureau of Prisons, et at, 19-CV-660 (MKB). 2 EFTA00040352 LAW OFFICES OF 13O13131 C. STERNHEIA\ anything like her current regime' The following conditions and cir

d by Judge Alison J. Nathan on 5/14/2021) (In') 1:20-cr-00330-AJN-1 Notice has been electronically mailed to: David Boies, II Jeffrey S. Pagliuca Laura A. Menninger Bobbi C Sternheim Christian R. Everdell EFTA00024709 --- PAGE BREAK --- Mark Stewart Cohen Sigrid S. McCawley [email protected] USANYS.E

acting her ability to prepare for and withstand trial. The Court sought more information by ordering the Government to confer with legal counsel for the Bureau of Prisons and to respond to certain questions. Dkt. No. 257. In response, the Government states that MDC staff conduct flashlight checks of all inmates as a

Case 1:20-cv-00484-JGK-DCF Document 79 Filed 09/04/20 Page 1 of 3 H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman. P.0 Laura A. Menninger ISO East 10th Avenue Denver. Colorado 80203 rti 303.831.7364 rx 303.832.2628 www.hmflaw.com Imenningerehmflaw.com September 4, 2020 VIA ECF H

and the demands on a party in a civil litigation: First, Ms. Maxwell cannot be deposed based on the current limitations put in place in the MDC by the Bureau of Prisons. Second, Ms. Maxwell cannot participate in any other party or witness deposition. Third, Ms. Maxwell cannot receive, review, edit or comment on pl

n R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00018515 ---

navirus cases.; In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and I Timothy Williams, et al., Co

internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and iss

Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim October 8, 2020 Re: United

cell. In response, MDC legal counsel indicated that the defendant will be required to sleep in the isolation cell. According to MDC legal counsel, the Bureau of Prisons ("BOP") and MDC still feel that this is the most appropriate placement for the defendant, both for her safety and the security of the institution.

rk 10007 October 8, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi

20 call, MDC legal counsel has indicated that the defendant has received all mail that the MDC has received addressed to her and in compliance with Bureau of Prisons ("BOP") regulations. MDC legal counsel confirmed that letters sent on colored paper do not comply with BOP regulations and would be rejected. If a l